ML20205E009

Informs of Status of Mods Committed to in 850401 Ltr (Per App R) & Forwards Changed Pages to Repts 3 & 4.Mod Proposed to Install Disconnect Switches to Interrupt Potential Faults That Could Cause Valves FV-2205 & FV-2206 to Close

ML20205E009
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/26/1985
From:	Lee O PUBLIC SERVICE CO. OF COLORADO
To:	Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
P-85341, NUDOCS 8510170171
Download: ML20205E009 (10)

Text

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20;2-l1 h Public Service-September 26, 1985 P.O. Box 84o Denver, co 80201 0840 Fort St. Vrain Unit No. } OSCAR R. LEE P-85341 VICE PRESIDENT o Iy $ $ $ 0E/ P

U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 DCT - 7l985 .

~~"

Attn: Mr. Dorwin Hunter Docket No. 50-267

SUBJECT:

10CFR50, Appendix R Fire Protection Evaluation

REFERENCES:

1) PSC Letter, Lee to Johnson, dated January 17, 1985 (P-85010),ReportNo.3

2) PSC Letter, Lee to Johnson, dated April 1,1985 (P-85113),ReportNo.4

Dear Mr. Hunter:

This letter is to inform you of the status of various modifications committed to in Reference No. 2, and to forward to you 20 copies of pages changed to Report No. 3 (Reference No. 1) and Report No. 4 (Reference No. 2) reflecting the changes also contained in this correspondence. Per the commitment in Section 4.3 of Report No. 4,

! fire dampers have been installed at the wall penetrations to bring l this up to a complete 3-hour barrier. This work was completed September 9, 1985.

Under Section 4.11 of Report No. 4, sub-section(a), a modification was proposed to install disconnect switches to interrupt potential faults that could cause valves FV-2205 and FV-2206 to close. The scope of this modification has been changed to now provide operability thru the use of a back-up hydraulic power supply I (accumulator) for each valve. With this back-up system, the l isolation of the actuator's normal supply piping and the positioning i of the FV in the open position can be accomplished in one location.

As this is a major change in scope, and extended lead time is required for manufacture of parts, it is necessary to revise our date to have the Change Notice and material on site to March 1, 1986. The page changes to Report 4 are attached documenting this modification j[ -

v, g D 8510170171 850926 [O PDR ADOCK 05000267 (6 F PDR

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Also under Section 4.11 of Report No. 4, sub-section (d), PSC committed to provide by-pass valves to allow venting of the static seal and releasing of the brake for the circulator being used. It has been determined following i Arther research that existing manual vent valves exist that will allow the action required. Therefore, this modification is no longer necessary and the affected pages of Report No. 3 and Report 4 are attached with the reference to this modification deleted.

If you have any further questions regarding this matter, please contact Mr. M. H. Holmes at (303) 571-8409.

Very tru y yours, O. R. ee, Vice President Electric Production ORL/FT:pa l

l

w interpretations of Appendix R requirements. Various alternative measures may be taken to resolve these deficiencies, including procedural changes, facility modifications, and exemption requests. Proposed changes and exemption requests will be contained in Report No. 4. The purpose of the following is to summarize the deficiencies identified as a result of the volve accessibility and I operability review.

l. The following valves require a lodder for access:

4 V-2II2l4 V-4234 LV-2138 V-42390 V-3fl01 V-42817 i HV-31122 V-46614 i HV-31191

2. Valves PV-22153 and PV-22154 ore not accessible; valves foil close, but require opening for shutdown model.

3. Valves FV-2205 and FV-2206 are hydraulic volves, with no local manual control capability. These volves fait closed on loss of electrical, and fail-os-is on loss of hydraulic power; open position is required for shutdown model, i

I i- ,

3 O

DC-84-26 6-2 Rev.2 '

?

q (k) Turbine Water Removal Pumps - As noted in 4.9 above, Q the Train B power cable feeding the transfer switch will be re-routed to provide a horizontal separation of greater than 30 feet.

4.1i VALVE OPERABILITY The following changes and modifications will be made to provide operability of volves whose controls could be adversely offected due to a fire, and to improve volve accessibility:

(a) Accumulators - Accumulators will be provided for volves FV-2205 and FV-2206. The occumulatcrs will be provided with manually operated valves that will isolate the normal hydraulic system and valve in the occumulator which will have st,fficient stored energy to open the valves even if fully closed.

(b) Valve Operator Air Bottles - Air bottles will be provided to allow local manual operation of volves PV-22153, PV-22154, LV-21303, and LV-21304. (2.28)

(c) Local Control Valve - The air isolation and bleed volve for TV-2227-3 will be relocated to a more readily acces-sible location. (2.28)

(d) Ladders - Ladders have been provided for valves that were identified to be not readily accessible. The ladders will be secured nearby to the valve location. (2.28)

(e) Valve Tagging - Large readable togs will be provided for valves requiring local manual operations.

4.12 SERVICE WATER RETURN PUMP CONTROLS To eliminate the dependency on 120 volt AC instrument bus 2 at I-64, the following change will be made to the controls for service water return pump 1B.

The contact from LS-4208-2 will be changed from on "a" to "b," so LS-4208-2X3 l

r i

O DC-85-04 4-7 Rev.I

. l 1

i 3 o Accumulators - A special repair procedure will be l prepared to identify actions to be taken to allow these volves to go to their required position. l i o Volve Operator Air Bottle - The LV's are required for high pressure drain of the required circulator. Local manual operations of these LVs would only be required if loss of steam drive capability to all circulators occurs, closing of the LV were to occur for the required circula-tor, and loss of function of all three of the other circulators occurs. It is extremely unlikely that all of these events would occur and thus require local operation of an LV. The PV's are each associated with a steam generator loop. For the steam generator loop being used, any one of three volves is required to be opened to use the EES section to flow through the decay heat removal heat exchanger. It is unlikely that a fire would cause loss of all three volves in each steam generator loop. The extremely low likelihood of the occurrence of events requiring local manual operation of these volves in the relatively short time period until availability of the air bottle provides reasonable assurance that shutdown opera-ticas will be performed.

o Local Control Valve - Valve TV-2227-3 presently has air isolation and bleed volves. The modification is on enhancement to better facilitate operability. Accord-

. ingly, adequate interim capability is provided by the present air isolation and bleed volves.

o Ladders - Other ladders are presently available and could be used in the interim period until additional ladders are provided. The new ladders will facilitate performance of required manual operation. With the availability of other ladders and the short time period until availability i of additional ladders, odequate capability is available in the interim period.

o Valve Tagging - Valves are presently tagged with stamped metal tags. The large togs are on enhancement to facilitate location and operation of volves. With the short the period until completion of the retagging and the present togging that is ovalloble, sufficient measures are available in the interim period.

o Service Water Return Pump Controls - Even if the ser-vice water return pumps were not available due to damage to their control circuits, the service water return sump could be allowed to overflow to the yard area, with V) t DC-85-04 4-13 Rev.I

TABLE 4-1 .

(continued)

Length of Required Change Notice and Plant Shutdown Completion item Description Material On Site (Days) Date 4.10 (d) Feedwater Flow Monitoring Oct.15,1985 14 (e) Feedwater Flow Associated Cables Oct. I,1985 14 (f) ACM fuel Oil Transfer Pump Dec.15,1985 14 (g) Helium Flow inst. Cables Dec.30,1985 14 (h) Main Steam Temp. Indic. Jan.15,1986 14 (i) Bearing Water Pumps Feb.15,1986 14 (j) Emergency Water Booster Pump Mar.15,1986 14 4.11 Valve Operability

_(a) Accumulators March 1,1986 14 l (b) Volve Operator Air Bottles June I,1985 I4 (c) Local Control Volve June I,1985 14 (d) Lodders June I,1985 0 July 15,1985 (e) Valves Togging June I,1985 0 July 15,1985 1

i DC-85-04 Rev.I

l

. i I

p., interpretations of Appendix R requirements. Various alternative measures may i V be taken to resolve these deficiencies, including procedural changes, facility l modifications, and exemption requests. Proposed changes and exemption requests will be contained in Report No. 4. The purpose of the following is to summarize the deficiencies identified as a result of the valve accessibility and operability review.

1. The following valves require a ladder for access:

V-211214 V-4234 i

LV-2138 V-42390 V-31101 V-42817 HV-31122 V-46614 l HV-31191

2. Valves PV-22153 and PV-22154 are not accessible; valves fail close, but require opening for shutdown model.

3. Valves FV-2205 and FV-2206 are hydraulic valves, with no local manual control capability. These valves fail closed on loss of electrical, and fail-as-is on loss of hydraulic power; open position is required for shutdown model.

i i

l I

l DC-84-26 6-2 Rev.2 i 3

i

~

(k) Turbine Water Removal Pumps - As noted in 4.9 above, O, the Train B power cable feeding the transfer switch will be re-routed to provide a horizontal separation of greater than 30 feet.

4.1I VALVE OPERABILITY The following changes and modifications will be made to provide operability of volves whose controls could be adversely offected due to a fire, and to improve volve accessibility:

(a) Accumulators Accumulators will be provided for vnives FV-2205 and FV-2206. The occumulators will be provided with manually operated volves that will isolate the normal hydraulic system and volve in the occumulator which will have sufficient stored energy to open the volves even if fully closed.

(b) Valve Operator Air Bott9s - Air bottles will be provided to allow local manual operation of volves PV-22153, PV-22154, LV-21303, and LV-21304. (2.28)

(c) Local Control Volve - The air isolation and bleed voive for TV-2227-3 will be relocated to a more readily acces-sible location. (2.28)

(d) Ladders - Ladders have been provided for volves that were identified to be not readily accessible. The ladders will be secured nearby to the volve location. (2.28)

(e) Volve Tagging - Large readable togs will be provided for volves requiring local manual operations.

4.12 SERVICE WATER RETURN PUMP CONTROLS To eliminate the dependency on 120 volt AC instrument bus 2 at I-64, the following change will be made to the controls for service water return pump 18.

l The contact from LS-4208-2 will be changed from on "a" to "b," so LS-4208-2X3 I

r l

U DC-85-04 4-7 Rev.I

g o Accumulators - A special repair procedure will be l g' prepared to identify actions to be taken to allow these valves to go to their required position. l o Valve Operator Air Bottle - The LV's are required for high pressure drain of the required circulator. Local manual operations of these LVs would only be required if loss of steam drive capability to all circulators occurs, closing of the LV were to occur for the required circula-tor, and loss of function of all three of the other circulators occurs. It is extremely unlikely that all of these events would occur and thus require local operation of an LV. The PV's are each associated with a steam generator loop. For the steam generator loop being used, any one of three valves is required to be opened to use the EES section to flow through the decay heat removal heat exchanger. It is unlikely that a fire would cause loss of all three valves in each steam generator loop. The extremeiy low likelihood of the occurrence of events requiring local manual operation of these valves in the relatively short time period until availability of the air bottle provides reasonable assurance that shutdown opera-tions will be performed.

o Local Control Valve - Volve TV-2227-3 presently has air isolation and bleed valves. The modification is on enhancement to better facilitate operability. Accord-y ingly, adequate interim capability is provided by the present air isolation and b!eed volves.

o Ladders - Other ladders are presently available and could be used in the interim period until additional ladders are provided. The new ladders will facilitate performance of required manual operation. With the availability of other ladders and the short time period until availability of odditional ladders, odequate capability is available in the interim period.

o Valve Togging - Volves are presently tagged with stamped metal tags. The large tags are on enhancement to facilitate location and operation of valves. With the short time period until completion of the retagging and the present tagging that is available, sufficient measures are available in the interim period.

o Service Water Return Pump Controls - Even if the ser-vice water return pumps were not available due to domoge to their control circuits, the service water return sump could be allowed to overflow to the yard area, with l

l (3

O DC-85-04 4-13 Rev.I 1

TABLE 4-I (continued) ,

4 Length of Required 1 Change Notice and Plant Shutdown Completion Description Item Material On Site (Days) Date 4.10(d) Feedwater Flow Monitoring Oct.15,1985 14 (e) Feedwater Flow Associated Cables Oct.I,1985 14 (f) ACM fuel Oil Transfer Pump Dec.15,1985 14 (g) Helium Flow Inst. Cables Dec.30,1985 I4 (h) Main Steam Temp. Indic. Jan.15,1986 14 (i) Bearing Water Pumps Feb.15,1986 14 (j) Emergency Water Booster Pump Mor.15,1986 14 4.11 Valve Operability (a) Accumulators March I,1986 14 l (b) Valve Operator Air Bottles June I,1985 I4 (c) Local Control Volve June I,1985 14 (d) Lodders June I,1985 0 July 15,1985 i

(e) Volves Togging June I,1985 0 July 15,1985 l

I l

DC-85-04

Rev.I

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